On December 10, 2013, federal agencies issued final regulations under the Volcker Rule (Rule), which is part of the Dodd-Frank Act. The Rule’s primary goal is to limit systemic risk by prohibiting proprietary trading by banks. In short, the Rule prohibits “banking entities” from engaging in proprietary trading and from holding interests in certain “covered funds.” Given the broad definitions of “banking entity” and “covered fund,” many European funds and other foreign financial institutions are likely to be affected by the Rule. A recent program presented by the financial services group of law firm Dechert LLP and the European Fund and Asset Management Association (EFAMA) discussed the potential impact of the Rule on European fund managers. The program featured Jarkko Syyrilä, Deputy Director General of EFAMA, and Dechert LLP partners Karen L. Anderberg, Julien Bourgeois, David J. Harris and David A. Vaughan. For insight from Vaughan previously published in the HFLR, see “A Practical Guide to AIFMD Reporting for Non-U.S. Fund Managers: Reporting Under AIFMD versus Form PF
,” Hedge Fund Law Report, Vol. 6, No. 20 (May 16, 2013); and “Form PF: Operational Challenges and Strategic, Regulatory and Investor-Related Implications for Hedge Fund Managers
,” Hedge Fund Law Report, Vol. 5, No. 4 (Jan. 26, 2012).